ACCEPTED
01-15-01080-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/19/2016 3:18:41 PM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 01-15-01080-CR
HAROLD EARL REED, § IN THE COURT OF APPEALS
FILED IN
1st COURT OF APPEALS
Appellant § HOUSTON, TEXAS
VS. § IN HOUSTON, TEXAS
4/19/2016 3:18:41 PM
§ CHRISTOPHER A. PRINE
THE STATE OF TEXAS, § Clerk
1st JUDICIAL DISTRICT
Appellee
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, HAROLD EARL REED, Appellant, and files this Motion for
Extension of Time to File Appellant's Brief, pursuant to Rules 10.5(b) and 38.6(d),
Texas Rules of Appellate Procedure. In support of this Motion, Appellant would
show the following:
I.
Appellant’s brief was due to be filed on April 18, 2016. Counsel for Appellant
requires an extension of one (1) day within which to complete and file Appellant’s
brief in this cause. This is Appellant’s second request for extension of time.
II.
Counsel for Appellant has worked diligently on the brief since receiving the
record, but has been unable to complete it for the following reasons:
1. Counsel for Appellant’s office was closed on April 19, 2016 due to
the flash flood emergency in Harris County, Texas and surrounding areas.
III.
This request is not made for the purpose of delay, but rather this request is
made to allow counsel adequate time to prepare Appellant’s Brief. Appellant
moves this Court for an order granting an extension of one (1) day, or until April
19, 2016 for Appellant to submit the brief in this case.
WHEREFORE, PREMISES CONSIDERED, Appellant moves this Court
for an order granting an extension of one (1) day for Appellant to submit the brief
in this case.
Respectfully submitted,
/s/ Nicole DeBorde
NICOLE DEBORDE
TBA No. 00787344
712 Main Street, Suite 2400
Houston, Texas 77002
Telephone: (713) 228-8500
Facsimile: (713) 228-0034
Email: Nicole@BSDLawFirm.com
COUNSEL FOR APPELLANT,
HAROLD EARL REED
CERTIFICATE OF COMPLIANCE
Pursuant to Rule 9 of the Texas Rules Appellate Procedure, the undersigned
counsel of record certifies that the motion contains 481 words.
/s/ Nicole DeBorde
NICOLE DEBORDE
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion
for Extension of Time to File Appellant's Brief was delivered via email to Alan
Curry, (curry_alan@dao.hctx.net) to the Harris County District Attorney's Office,
Appellate Division, 1201 Franklin, Suite 600, Houston, Texas 77002 on this the 19th
day of April, 2016.
/s/ Nicole DeBorde
NICOLE DEBORDE
CAUSE NO. 01-15-01080-CR
HAROLD EARL REED, § IN THE COURT OF APPEALS
Appellant §
VS. § IN HOUSTON, TEXAS
§
THE STATE OF TEXAS, § 1st JUDICIAL DISTRICT
ORDER
On this the _____ day of _______________, 201___, came on to be heard the
Appellant's Motion for Extension of Time to File Appellant's Brief and the Court is
of the opinion that this Motion should be:
GRANTED, and the deadline for filing the Appellant's brief in Cause No. 01-
15-01080-CR is extended to ____________________, 201__.
DENIED, to which action of the Court the Appellant objects.
SIGNED this the _____ day of _______________, 201__.
__________________________________
JUDGE PRESIDING